Handling Economic Impact Payments

According to the U.S. Treasury and the Federal Reserve, Economic Impact Payment (EIP) ACH files are being originated. The Treasury’s Bureau of Fiscal Service anticipates continuing to transmit economic impact payments every Friday, as additional payment information becomes available.

Here’s what we know about the formatting of the EIP payments:

  • Payments will look EXACTLY like Federal tax returns with the Company Name including "IRS TREAS 310" and Company Entry Description including "_TAX REF"
  • Treasury will be using the following RTNs to send ACH EIPs:
    • 111036170
    • 111736946
    • 111736959
    • 111736043
    • 111736056
    • 111736069
    • 111736072
    • 111736085
    • 111736098
    • 111736108

The IRS is determining eligibility for EIPs before the payments are sent. We have been advised that payments to recipients who died after 12/31/2019 should not be returned. We are working round-the-clock to make sure the information we are providing our members is current and correct. However, with the tight turnaround of the disbursement of these EIPs, this information is changing just as quickly as it is being released. We encourage you to watch the Knowledge Community for the most up-to-date information.

We are advising EPCOR members that all Green Book and ACH Rules for Federal non-benefit payments (specifically from the IRS) apply when posting all EIPs.

This includes:

  • Returning IRS payments to closed or frozen accounts.
  • Returning IRS payments for invalid or incorrect account numbers.
  • Posting IRS payments to open accounts for deceased beneficiaries or representative payees.
  • Posting IRS payments to overdrawn accounts.
  • Returning IRS payments refused by account holders.

The way a financial institution handles these situations should be based on three things:

  • The institution's policies for posting and returning IRS tax refunds
  • The ACH Rules
  • The Green Book

These Federal non-benefit payments are not subject to reclamation, and garnishment policies for Federal non-benefit payments can be applied to payments. Just as any payment from the Federal government, it is not the responsibility of the financial institution to determine eligibility of the payment.

We have been in constant communication with Treasury and Nacha, and all agree that the ACH Rules and the Green Book have not changed, even with these unique Federal government payments.

The IRS says the vast majority of people do not need to take any action. The IRS will use 2019 tax return information to calculate the payment amount, and Direct Deposit that payment into the same banking account reflected on the return filed. If a 2019 return has not been filed, then the IRS will use 2018 tax return information.

However, there are some individuals who will need to take action:

  • People who typically do not file a tax return will need to file a return to receive an economic impact payment. The IRS will automatically send an EIP to people who receive Social Security, Railroad Retirement or SSDI benefits.
  • Anyone with a tax filing obligation who has not yet filed a tax return for 2018 or 2019 will need to file to receive an economic impact payment.

The U.S. Treasury has developed a web-based portal here for individuals to provide their banking information to the IRS online, so that individuals can receive payments more quickly by Direct Deposit as opposed to checks in the mail. All financial institutions should consider how to provide or make this information available to their clients opting to do this.

Finally, Nacha urges everyone to be mindful of the potential for fraudsters to take advantage of this National Emergency in general, and these economic impact payments in particular.

Additionally, you’ll find more information on Nacha’s Current Fraud Threats page. Or, for more information on fraud related to COVID-19, check out of Did You Know video on YouTube or our website.

Corrected Information for Economic Impact Payments

Recently, the IRS said via Twitter that it had “deposited the first Economic Impact Payments into taxpayers’ bank accounts.” In actuality, the IRS had transmitted, via the U.S. Treasury, the first of several files of ACH credits to the Federal Reserve for this first round of Economic Impact Payments. The IRS tweet resulted in some coverage by the news media, as well as account holder contacts to financial institutions asking about the status of their own payments.

That evening, Nacha contacted the U.S. Treasury to express their concern, and to ask for the original tweet to be deleted, or for correcting information to be issued. By the next morning, the IRS said that they will adjust the existing tweets where they can and to future planned tweets.

The following Q&A can be used by any financial institution needing to answer customer inquiries, or to provide internal messaging:

Question: The IRS says it has “deposited” money into taxpayers bank accounts, but I don’t have my money yet. What’s going on?

Answer: The IRS will be sending Economic Impact Payments over the next several weeks to those eligible. The first wave, an estimated 81 million payments, included many of those who have provided their bank account information through filing their taxes in 2018 or 2019 or through other federal programs. Not all of the payments have been sent yet.

It is the IRS that determines when payments are made, and we will not know which round anyone is in until we receive their payment. Some people might be getting payments in future rounds. Many recipients will receive payments via check, and those are expected to be delivered over several weeks.

Sources: Nacha & U.S. Treasury